ROC Compliance Update: Annual Return Filing under MCA V3 Portal

By Komal Sethia, Team Leader – ROC Compliance, Sandeep Ahuja & Co.

Applicable for Annual Filings Due on or after 14th July 2025

Compliance with annual filing requirements under the Companies Act, 2013 is a statutory obligation for all companies. As per Section 137 of the Companies Act, 2013 read with Rule 12(1) of the Companies (Accounts) Rules, 2014, companies must file annual financial statements with the Registrar of Companies (ROC).

From 14th July 2025, the MCA has fully transitioned to the V3 web-based portal, replacing the older V2 PDF download/offline submission process. The new portal ensures pre-filled data, integrated forms, enhanced validations, and streamlined compliance tracking.

Key Updates for FY 2024–25 Annual Filings

1. Full Migration to MCA V3 Portal

   • V3 supports online filing and offline preparation via Excel utility, which can be uploaded directly to the portal.

2. “Review, Not Re-Create” Approach

   • Pre-filled data from the previous year allows companies to review and correct previous data, improving accuracy and reducing duplication.

3. Integrated Forms & Attachments

   • AOC-4 – Financial Statements (Standalone/Consolidated)

   • AOC-2 – Related Party Transactions

   • Director’s Report

   • Auditor’s Report

   • Other related forms (CRA, ADT series) are linked in the filing workflow.

4. Enhanced Portal Features

   • Pre-filled data ensures accurate year-on-year comparisons.

   • Offline Excel utility allows work without internet connectivity.

   • “My Applications” dashboard replaces “My Workspace” for improved status tracking.

   • Stricter validation checks: DIN, PAN, consistency of figures, and attachments reduce rejections.

5. New Compliance Requirements

   • Photograph of the registered office showing the company name board and at least one director.

   • All amounts must be in absolute rupees (no rounding off).

   • V3 enables linking pre-merger filings in case of amalgamation/demerger.

6. Transition & Downtime Considerations

   • V2 “Pay Later” option disabled from 8 June 2025.

   • V2 portal offline from 18 June 2025.

   • V3 portal downtime: 9–13 July 2025; no filings accepted and no relaxations allowed.

   • Pending SRNs must be cleared before migration to avoid cancellation.

Step-by-Step Filing Procedure for AOC-4

1. Login

   • Access MCA V3 Portal using valid credentials.

2. Navigate to Form AOC-4

   • MCA Services → Company e-Filing → Annual Filings → Form AOC-4.

3. Enter Company Details & Attach Documents

   • Input CIN and company details.

   • Attach:

     • Financial Statements (Standalone / Consolidated)

     • AOC-2 – Related Party Transactions

     • Director’s Report

     • Auditor’s Report

4. Submit Webform

   • Draft can be saved.

   • Submit online for SRN generation.

5. Digital Signatures (DSC)

   • Download PDFs (AOC-4 + linked forms).

   • Affix DSCs of Director and Practicing Professional.

6. Upload & Payment

   • Upload DSC-signed PDFs.

   • Pay applicable fees.

   • Acknowledgement generated post-payment.

Verification of Annual Forms

• Submitted forms can be downloaded from “My Applications → Pending for Action”.

• Verification requires DSCs of Director and the Professional certifying the financial statements.

Due Dates for AOC-4

Company Type	Due Date
General Companies	Within 30 days of AGM (e.g., AGM on 30th Sept → filing by 30th Oct)
One Person Companies (OPC)	Within 180 days from FY end (e.g., FY end 31st Mar → filing by 27th Sept)

No extension will be granted if the due date falls during V3 portal downtime.

Fee Structure for Filing Form AOC-4

Paid-up Capital	Normal Fee (₹)
Less than 1,00,000	200
1,00,000 – 4,99,999	300
5,00,000 – 24,99,999	400
25,00,000 – 99,99,999	500
1,00,00,000 or more	600

Additional Fee for Late Filing: ₹100 per day.

Key Takeaways

• MCA fully migrated to V3; V2 PDF method is obsolete.

• Pre-filled forms and linked attachments simplify filing and reduce errors.

• Ensure DSC of both Director and Professional on all forms.

• Strict adherence to due dates is essential to avoid additional fees.

• Review previous year’s pre-filled data carefully.

• New requirements: photograph of registered office, absolute figures, merger/demerger linking, and enhanced validation checks.

Pro Tip: Early preparation, use of offline Excel utility, and verification of pre-filled data can save time, reduce errors, and avoid late fees.